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FCTD

CCLC Technologies Inc. v. R., [1996] 1 CTC 7, 95 DTC 5685

That was to be completed by December 31, 1993, although as of the date of this hearing it had not occurred. ...
FCTD

Edwin J. Byram v. Her Majesty the Queen, [1995] 1 CTC 66, [1995] DTC 5069

The Queen, [1993] 2 C. T.C. 3027, 94 D.T.C. 1061. The plaintiff urges the Court to consider the oral reasons of Judge Bell, as a means of resolving, what the plaintiff submits is the issue to be determined, namely, whether the plaintiff’s loans, and subsequently acquired debt, were "for the purpose of gaining or producing income from a business or property" within the meaning of subparagraph 40(2)(g)(ii). ...
FCTD

Ilori v. Canada (Citizenship and Immigration), 2021 FC 627

The focus of the third test, the Koo qualitative test, is the location in which the person applying for Canadian citizenship “regularly, normally or customarily lives”: Miji, at para 19, citing Koo (Re), 1992 CanLII 2417 (FC), [1993] 1 FC 286 (TD). ...
FCTD

Krispy Kernels v. Deputy Minister of National Revenue, [1998] 1 CTC 108

The parties to this action have agreed that the facts and evidence upon which the action should proceed are set forth in the transcript of evidence before the CITT, dated June 2, 1993. ...
FCTD

Huang & Danczkay Ltd. v. Minister of National Revenue, [1998] 3 CTC 337, 98 DTC 6393

.: The Plaintiff, her Majesty the Queen (the “Minister”), appeals the decision of the Tax Court of Canada, dated 17 June 1993, whereby the Defendant’s appeal in respect of its 1980, 1981, 1983 and 1985 taxation years was allowed. ...
FCTD

Braceland v. Revenue Canada Fairness Group Appeals, [1999] 3 CTC 343, 99 DTC 5189

Minister of National Revenue (1993), 68 F.T.R. 157 (Fed. T.D.). In Floyd supra, which was cited with approval in Bourgeois v, Revenue Canada (1996), 96 D.T.C. 6304 (Fed. ...
FCTD

Aronson v. Canada (National Revenue), 2021 FC 1451

In February 2016, the CRA issued reassessments and the Applicant settled her remaining debt of $6,100 in April 2016 in full. [9] In June 2016, counsel for the Applicant submitted a request for taxpayer relief for the 1993 to 2015 taxation years. ...
FCTD

Ministre Du Revenu National v. Intermodal Container Transport Ltée, [1999] 4 CTC 303, 99 DTC 5619

Lacaille (1992), [1993] R.D.J. 284 (Que. C.A.), at page 288: [Translation] First, it should be explained that the trial judge was correct when he wrote that allowing the appellants to prove that writings P-1 and P-2 were executed subject to an unwritten term would amount to “altering” the terms of these writings. ...
FCTD

Iris Technologies Inc. v. Canada (National Revenue), 2022 FC 1404

Typically, mandamus will issue only if the respondent has a non-discretionary duty to act (Apotex Inc v Canada (Attorney General), 1993 CanLII 3004 (FCA), [1994] 1 FC 742 (CA) at 766-769 [Apotex], affirmed 1994 CanLII 47 (SCC), [1994] 3 S.C.R. 1100). ...
FCTD

Adams v. R., [1998] 2 C.T.C. 333, (sub nom. R. v. Robinson) 98 D.T.C. 6232

Paul: West Publishing, 1993) at 311. 19 I can see no basis on which to hold that the eighteen co-owners were acting in a different capacity when they agreed through their agent to pay themselves a tenant inducement payment. ...

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